Ey Cross-border Taxation Alerts

A review of the week's major US international tax-related news. In this edition: US House approves tax bill; Senate action unlikely -- Congressional Joint Committee on Taxation releases general explanation of the Tax Cuts and Jobs Act (Blue Book) – IRS issues proposed regulations on Sections 245A(e) and 267A – IRS issues proposed regulations under Section 864(c)(8) on tax treatment of foreign partners gains on sale of a US partnership interest – IRS Notice 2019-01 announces future regulations re: foreign corporations with PTEP -- OMB received proposed Section 250 regulations for review

A review of the week's major US international tax-related news. In this edition: US House tax leader releases modified year-end tax package -- IRS releases proposed Section 59A Base Erosion and Anti-Abuse Tax (BEAT) regulations – IRS issues Section 965 transition tax FAQs -- OMB completes review of proposed TCJA Section 864c()(8) regulations; release imminent – IRS issues proposed FATCA, withholding regulations – US Treasury issues another FBAR extension -- OECD will release major digital tax update end of January 2019

A review of the week's major US international tax-related news. In this edition: US Republican efforts to move tax legislation stall in House – US Treasury sends final Section 965 transition tax regulations, proposed regulations under Section 864(c)(8) to OMB for review – ECOFIN fails to reach agreement on proposed EU Digital Services Tax; US House tax leader weighs in

A review of the week's major US international tax-related news. In this edition: IRS issues proposed regulations on computing interest expense limitation under Code Section 163(j) – IRS releases complex foreign tax credit regulations – Congressional Republicans advance year-end tax legislation in lame-duck session

A review of the week's major US international tax-related news. In this edition: US, Singapore signed TIEA and new FATCA Model I IGA – OECD released update to 2017 Progress report on Preferential Tax Regimes – OECD Inclusive Framework on BEPS released substantial activities requirement for “no or only nominal tax” jurisdictions -- OECD now gathering input on implementation of BEPS Action 14 minimum standard for review of seventh batch of jurisdictions

A review of the week's major US international tax-related news. In this edition: IRS proposed regulations on related-party hybrid transactions / hybrid entities sent to OMB for review – Proposed Section 163(j) regulations release imminent -- Final Section 965 transition tax regulations will include detailed ordering rules for determining E&P – IRS Commissioner says expect more informal guidance – US House tax leader eying 70-80 TCJA technical corrections for lame-duck legislation

A review of the week's major US international tax-related news. In this edition: US mid-term election will affect tax in Congressional lame-duck and 2019 – Treasury sends TCJA’s BEAT and FTC proposed regulations to OMB for review -- EU Ministers meet on proposed Digital Services Tax

A review of the week's major US international tax-related news. In this edition: IRS proposed rules would reduce Section 956 inclusions for certain domestic corps owning stock in foreign corps -- IRS recently issued Section 163(j) draft Form 8990, draft instructions for BEAT Form 8991 – IRS LB&I issues 3 more international tax compliance campaigns -- US House tax leader issues warning about proposed UK DST, other unilateral measures – Netherlands announces intent to repeal Decree re: US-Netherlands tax treaty relation to hybrid entities

A review of the week's major US international tax-related news. In this edition: Proposed Section 163(j) regulations sent to OMB Office of Information and Regulatory Affairs for final review – US Treasury Secretary issues statement opposing unilateral digital tax action – Senate tax leaders express opposition to EC Digital Services Tax proposal – US, Israel to establish task force to review existing tax treaty

A review of the week's major US international tax-related news. In this edition: Proposed FTC and Section 163(j) regulations release to OMB Office of Regulatory Affairs imminent -- Proposed PTI regulations unlikely to be released as complete package by year-end – 2018 IRS deadline for QI, Withholding Foreign Partnership and Withholding Foreign Trust applications is 16 November 2018 – OECD making progress on digital tax framework

A review of the week's major US international tax-related news. In this edition: US government to release proposed regulations on most TCJA international provisions by year-end; finalization by June 2019 -- IRS to step-up action on withholding tax campaigns in new year -- OECD Forum on Harmful Tax Practices to review TCJA’s FDII later this month -- US official says OECD making good progress on long-term digital tax package

A review of the week's major US international tax-related news. In this edition: IRS Notice 2018-78 provides welcome amendments to Section 965 proposed regulations – IRS proposed regulations on GILTI to be published in Federal Register on 10 October 2018; 60-day comment period begins

A review of the week's major US international tax-related news. In this edition: US House moves forward with ‘tax reform 2.0’ – GILTI regulations to be finalized by June 2019 – IRS restructuring Advance Pricing and Mutual Agreement program.

A review of the week's major US international tax-related news. In this edition: US Treasury issues proposed regulations removing IRC Section 385 debt/equity documentation regulations – IRS releases draft Form 8991 on new Section 59A BEAT provision -- IRS Notice 2018-72 delays effective date of Section 871(m) dividend equivalent payments by two years – US House tax leader urges IRS to issue virtual currency guidance – OECD issues additional CbCR guidance.

A review of the week's major US international tax-related news. In this edition: IRS releases proposed Section 951A GILTI regulations – IRS issues guidance on REIT Section 951A, foreign currency income inclusions – House tax writing committee approves Tax Reform 2.0

A review of the week's major US international tax-related news. In this edition: US Congress returns for pre-election session – House tax-writing committee to move Tax Reform 2.0 week of 10 September

A review of the week's major US international tax-related news. In this edition: OECD released fourth round of BEPS Action 14 peer reports on improving tax dispute resolution mechanisms.

A review of the week's major US international tax-related news. In this edition: US Treasury sends TCJA’s global intangible low taxed income (GILTI) regulations to OMB for review – IRS issues draft forms for GILTI, foreign derived intangible income (FDII) provisions

A review of the week's major US international tax-related news. In this edition: Second Circuit Court of Appeals affirms district court decision in Trusted Media Brands, Inc. v. USA -- Eighth Circuit Court of Appeals vacates 2017 Tax Court order in Medtronic, Inc. v. Comm’r

A review of the week's major US international tax-related news. In this edition:US Ninth Circuit withdraws opinion in Altera – US Tax Court rules partnership’s Section 1446 withholding tax liability is a partnership item – Congressional Republicans urge President Trump to nominate OECD ambassador